Privacy Policy - December 9, 2019

Sunwire Inc. (the "Company", "we", "us" or "our") is dedicated to establishing trusting relationships with our Users by respecting information that we collect, use, and disclose that identifies a User or where there is a serious possibility that a User could be identified through the use of that information, alone or in combination with other information (“Personal Information”) and by promoting the use of fair information practices. For purposes of this Privacy Policy (“Policy”), "Services" is defined as any and all services provided by Company’s Customer Service, the Sunwire Web Site ("Site"), and all services offered now or in the future and "Sunwire account" is defined as the account through which you access the Services.

The Company collects Personal Information from users of the Services (“Users”, “you”, or “your”) at several different points through use of the Services.

1.1. Registration: In order to use the Services, you must first complete the registration process on the Site. During registration you are required to provide contact information (such as name, phone numbers, and email address), service information (service types, service addresses) and billing information. We use this information to contact you about the Services, bill you for the Services and other services offered by the Company for which you have expressed interest or that you might be interested in. We send all new Users a welcome email to verify their information. We might also contact you by other communication channels such as telephone, text messages, or direct mail.

1.2. Product Updates, Newsletters, Service Announcements: We might also send you emails or newsletters which contain usage tips, product updates or updates to the Terms of Service or this Policy. If necessary, we will also send you Service-related announcements. For instance, if a Service is temporarily suspended for maintenance, we may send Users an email. Users cannot opt-out of these nonpromotional communications unless they deactivate their services.

1.3. Customer Service: We communicate with Users on a regular basis to provide requested Services and regarding issues relating to Users' accounts or Services. We reply via email, phone, Web chat or other available method, in accordance with the User's wishes.

1.4. Referral Program: If a user elects to use our referral service for informing a friend about our Services, it is the User’s responsibility to ensure they have the consent of the friend in order for the User to submit the friend’s personal information to us. We ask for the friend's name and email address. We will automatically send the friend a one-time email on your behalf inviting them to visit the Company's Site. The Company stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

1.5. Cookies: A cookie is a piece of data stored on the User's computer tied to information about the User. We may use both session ID cookies and persistent cookies. For the session ID cookie, once Users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the User's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. Usage of a cookie is not linked to any Personal Information while on the Site except if you choose to store your user name and password so that you do not have to enter it each time you access your account. Then a persistent cookie will be stored on your computer, which is linked to your account information.

If you reject the persistent cookie, you may still use the Site but you will be limited in some areas of it. Persistent cookies also enable us to track and target the interests of our Users to enhance their experience on the Site.

1.6. Log Files: Like most Web sites, our servers use log files to analyze trends, administer the Site, track Users' movements in the aggregate and gather broad demographic information for aggregate use. These log files are not linked to Personal Information.

1.7. Clear Gifs: Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and we may use them to track the online movements of our Users. Clear gifs are invisible on the page and are much smaller than cookies, about the size of the period at the end of this sentence. Clear gifs are not tied to Users' Personal Information. We may also use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications.

1.8. Children’s Privacy: We do not knowingly collect personal information from children under the age of 13. If we learn that we have personal information of a child under the age of 13, we will delete that information from our systems. For tips on protecting children's privacy online, please visit the FTC's Website: ( http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/index.html ).

2. Disclosure of Personal Information

2.1. Legal, Security and Safety: Except as stated in this Policy or in an agreement with you, we do not disclose Personal Information about our Users or monitor, edit or disclose the contents of a User's private communications through the Services except where we have your consent, are permitted by law to do so, or in good faith believe that such action is necessary to: (1) comply with the law or where we have a good-faith belief that such disclosure is necessary to comply with a current judicial proceeding, a court order, or legal process served on us; (2) investigate, prevent, or take action regarding illegal activity; (3) protect and defend the rights or property of the Company; or (4) to protect the personal safety of our Users or the public. For example, we may disclose Personal Information to law enforcement, other government officials or third parties in response to criminal or civil court orders, warrants, or subpoenas.

2.2. Civil Subpoena Policy: To request User information from the Company in a civil case, you must serve the Company with a valid subpoena, court order or search warrant and agree to the Company's terms of compensation below. All civil subpoenas should be directed to:

Sunwire Inc.
850 Barrydowne Road
Sudbury, Ontario, Canada P3A 3T7

Upon receipt of a valid subpoena, court order, or warrant, it is the Company's policy, where permitted by law, to notify the User whose information is sought. In nonemergency circumstances, the Company will generally not produce the User’s information until approximately two weeks after receipt of the subpoena, court order, or warrant unless a formal objection is filed by the party seeking the information and agreed to by us or we are legally required to do so. The Company charges $90.00 per hour for research (plus additional fees if testimony or deposition is required), $0.25 per page, and $22.00 to respond via Federal Express. We will invoice the person or entity submitting the subpoena following receipt and the subpoena proponent must make payment within 15 days from the date of receipt of our invoice. Cheques should be made out to Sunwire Inc.

Note that the Company reserves the right to determine in its sole discretion the applicability of this Policy to any particular request for user information and, further, this Policy does not create any enforceable legal rights, either for our Users or for requesting parties.

2.3. Provision of Services: Certain technical processing of and access to Users’ email and their Services and their account information may be required by us and our Service Providers to: (a) provide the Services, including without limitation, routing and indexing the messages; (b) conform to connecting networks' technical requirements; (c) prevent or minimize disruptions to the Services; or (d) conform to other similar requirements.

2.4. Service Providers: Supplementation of Information: In order for us to properly fulfill our obligations to Users, it is necessary for us to use Service Providers and to supplement the Services we provide with information and services from third party sources. In addition, we may use Service Providers to host certain portions of our Site and to fulfill certain requests for information from or for our Users. These companies do not retain, share, store or use personally identifiable information for any secondary purposes and the information obtained from these third-party sources is maintained in a manner consistent with this Policy.

2.5. Business Transitions: In the event that we go through a business transition, such as a merger, being acquired by another company, or selling a portion of our assets, Users' Personal Information will, in most instances, be included as part of the assets transferred. If as a result of the business transition, the Users' Personal Information will be used in a manner different from that stated at the time of collection they will be given a choice not to have their information used in this different manner.

2.6. Surveys: Periodically, Users might be asked to participate in surveys. Participation in these surveys is completely voluntary and the User therefore has a choice whether or not to disclose information. The requested information typically includes contact information (such as name and address) and demographic information (such as postal code). Survey information will be used for purposes of monitoring or improving the use and satisfaction of the Company's Services. Users' Personal Information is not shared with third parties unless we give prior notice and a choice to opt-out. Though we may use a Service Provider to conduct these surveys, they may not use Users’ Personal Information for any secondary purposes.

2.7. Abuse; Spam and Junk Faxes: We have a zero-tolerance policy for abuse. While we cannot be responsible for external communications received through our Services, it is our intention to use all legally available means to prevent use of the Services for any illegal purpose, including but not limited to distribution and receipt of unsolicited commercial faxes ("junk faxes"). We also specifically restrict Users from taking any actions, which impose an unreasonable or disproportionately large load on the Company's resources. We ask that any Users who are annoyed by receipt of such junk faxes or otherwise impacted by illegal use of the Services to please report such activity to the Company's Customer Service toll free at 1-833-727-6777.

2.8. Security: We take every reasonable precaution to protect our User's Personal Information. When Users submit Personal Information via the Services, their Personal Information is protected both online and off-line.

2.9. While we use SSL encryption to protect sensitive Personal information online, we also employ security measures to protect Users’ Personal Information off-line. All of our Users' Personal Information is restricted in our offices. Only employees who need the Personal Information to perform a specific job (for example, our billing clerks or a Customer Service representative) are granted access to the relevant Personal Information. Finally, the servers that store Personal Information are in a secure environment.

2.10. Notification of Changes: We will occasionally update this Policy so that it remains relevant and current with changing technologies, applicable laws, our evolving business practices and the needs of our Users. We encourage you to periodically review this Policy to stay informed of how we manage your Personal Information. If any changes are made to this Policy, we will revise the "Last Updated" date that is indicated on the Policy.

If material changes are made that impact you, we will notify users by placing a prominent notice on the Site. Depending on the circumstances, we may also decide to send Users a notice electronically. If you continue to use the Services after notice of the change has been given, you will be deemed to have accepted such changes.

2.11. Data Retention: The time period for which we keep Personal Information varies according to how we use the Personal Information. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.

2.12. Access to your Personal Information: Upon written request, we will inform you whether or not we hold Personal Information about you and provide you with access to your information within a reasonable timeframe and at minimal or no cost in accordance with applicable laws. If you identify an inaccuracy or incompleteness in your Personal Information, we will amend your information and notify any third parties as required by applicable laws.

In certain situations, and depending on applicable laws, we may not be able to provide access to all of the Personal Information that we hold about you. For example, we may not provide access to information if doing so:

• would likely reveal personal information about a third party;
• could reasonably be expected to threaten the life or security of another individual;
• would reveal our or third party confidential information;
• includes information that is protected by solicitor or attorney client privilege; or
• includes information that was processed in relation to the investigation of a breach of an agreement or a contravention of a law.

In order to safeguard your Personal Information from unauthorized access, we may ask that you provide sufficient information to identify yourself prior to providing access to your Personal Information.

Depending on the circumstances and applicable laws, we may refuse to process certain access requests (e.g. access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).

2.13. Questions or concerns? How to contact us: We welcome your questions or comments regarding this Policy and the way we process your Personal Information. If you have any questions, concerns or wish to request access to your Personal Information pursuant to applicable privacy or data protection laws, please contact us either by email or in writing and we will use commercially reasonable efforts to respond:

by email:

info@sunwire.ca, or

write to us at:

Sunwire Inc.
850 Barrydowne Road
Sudbury, ON P3A 3T7